Breach of duty of fair representation--complaint can't proceed where grievor signed release, says the LRB  is the link to a recent LRB decision that provides good guidance on what the law is when a union and an employer settle a grievance and the grievor signs a release.  According to the LRB, absent circumstances that prove undue influence or duress, the  release  signed as part of the settlement will bar a complaint of a breach of duty of fair representation against the union.